U.S. Court of Appeals for the Eighth Circuit, 2004

Oyer v. Commissioner of Internal Revenue Service

Oyer v. Commissioner of Internal Revenue Service
U.S. Court of Appeals for the Eighth Circuit · Decided May 20, 2004
97 F. App'x 68

Counsel

John H. Trader, Trader & Sullivan, Kansas City, MO, for Appellant., Richard Farber, Eileen J. O’Connor, U.S. Department of Justice, Gretchen M. Wolfmger, U.S. Department of Justice, Office of Immigration Litigation, B. John Williams, Jr., Chief Counsel, U.S. Internal Revenue Service, Office of Chief Counsel, Washington, DC, for Appellee.

Oyer v. Commissioner of Internal Revenue Service

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Opinion of the Court

PER CURIAM.

This is an appeal from the Tax Court’s order granting summary judgment in favor of the Internal Revenue Service in taxpayers’ suit challenging the IRS’s determination that they were liable as transferees for taxes in the amount of approximately $90,000. The Tax Court held, inter alia, that the doctrine of res judicata barred taxpayers from contesting the *69amount owed because the court had previously entered stipulated decisions against taxpayers that determined the taxes that are the subject of the dispute here.

We have carefully examined the record and conclude that the Tax Court correctly applied the doctrine of res judicata in this case. We therefore affirm on the basis of its well-reasoned decision. See 8th Cir. R. 47B.

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